FAQ

If an EU legal act – regardless of whether it is harmonisation legislation – lays down safety-specific requirements for a specific risk posed by a product, only the requirements of that EU legal act apply to that product risk. If the product poses a further risk that is not regulated by the product-specific EU legal act, the provisions of the GPSR shall also apply. This is to ensure that only products that comply with product safety requirements in terms of all product risks are placed on the EU market.

This is the case, for example, with a cutting knife: cutting knives generally fall within the scope of Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food as well as the scope of the GPSR. Regulation (EC) No 1935/2004 contains certain safety requirements to prevent material contamination of food for a cutting knife as food contact material. However, Regulation (EC) No 1935/2004 does not contain any requirements to mitigate other risks that may arise, for example, from the sharpness or point of a cutting knife. With regard to the risk of injury due to the sharpness or point of the cutting knife, the requirements of the GPSR apply.

No, there is no such requirement under the GPSR. Distributors have no legal basis for demanding documents such as technical documentation and risk analysis from manufacturers. Where applicable, it must be examined on a case-by-case basis whether there are any deviating, effective contractual agreements that oblige manufacturers to disclose the risk analysis and technical documentation.

However, manufacturers are obliged to disclose these documents to the authorities and must retain them for a period of ten years.

If manufacturers discover that they have placed an unsafe product on the market, they must take the following measures:

• take immediate corrective action to restore the conformity of the product,
• inform consumers about the unsafe product and
• inform the market surveillance authorities about the unsafe product via the Safety Business Gateway.

Information for distributors:

Manufacturers must inform distributors about the corrective measures taken to restore conformity or the withdrawal or recall of an unsafe product. To this end, manufacturers must specify the exact product models affected by the safety issue. Manufacturers should provide distributors with clear instructions on how to handle the product, in particular how distributors should deal with unsafe products that they still have in stock and what information distributors should pass on to their customers.

In order to achieve the highest possible efficiency of corrective measures, manufacturers should always inform distributors of the safety issues surrounding a product model and the risks associated with using the product.

Information for consumers:

If manufacturers sell the unsafe product directly to consumers, they are obliged to inform consumers immediately and directly about how consumers can use the product safely. In this context, manufacturers must specify the exact product model and, if necessary, inform consumers about corrective measures to be taken.

In order to ensure as efficiently as possible that consumers follow the manufacturer’s instructions for the safe use of the product, manufacturers shall inform consumers about the cause of the product’s unsafe nature and the risks involved in using the product.

If safe use is not possible, manufacturers must inform consumers not to continue using the product. In such cases, manufacturers will usually recall the product. Notification of a product recall is made in accordance with a recall notice, which must contain the information specified in Article 36 of the GPSR. A template for recall notices is available in the annex to Implementing Regulation (EU) 2024/1435.

Manufacturers must affix at least the following markings to the product:

• Type, batch or serial number;
• Name, registered trade name or registered trademark of the manufacturer;
• Manufacturer’s postal address;
• Manufacturer’s electronic address
• If there is a single contact point and the postal address or electronic address differs from the manufacturer’s addresses, the postal address or electronic address of the single contact point must also be provided.

In individual cases, additional labelling may be required, for example safety precautions for the safe use of the product.

The GPSR does not contain any labelling requirements for distributors. Distributors are generally free to affix additional labels to the product to identify themselves as distributors. If both the manufacturer and the distributor are indicated on the product, the distributor must ensure that the manufacturer can still be clearly identified. In practice, the addition ‘Manufactured for [distributor information]’ is therefore often used for differentiation purposes. The addition ‘Manufactured by [manufacturer information]’ or ‘Manufacturer: [manufacturer information]’ should also be added before the manufacturer information.

The internet address is a form of electronic address within the meaning of the GPSR, which manufacturers must provide on their products as a means of contact for consumers. In the interests of efficient consumer protection, every contact address provided by the manufacturer must enable consumers to contact the manufacturer easily, simply and directly.

If manufacturers decide to label a product with an internet address as an electronic address, the internet address must consist of a link that leads directly to the manufacturer’s contact form. According to the EU Commission, simply referring to the manufacturer’s homepage is not permitted: ‘Electronic address refers to forms of direct communication – e.g. email or contact form on a website, allowing consumers to contact the company directly. It does not include static websites or telephone numbers.’¹

1. https://ec.europa.eu/safety-gate/#/screen/pages/obligationsForBusinesses last accessed on 07/08/2025. ↩︎

Manufacturers must always provide the following operating, assembly and safety information for their products:

• Clear instructions for safe use and, where applicable, assembly, installation and maintenance, usually in the form of an instruction manual. (The exact content and level of detail of the instructions depends on the specific product in each case. For example, instructions for assembly and installation are not usually required for a cutting knife.)
• Safety information

Instructions and safety information do not need to be included if consumers can use the product safely and as intended by the manufacturer without the instructions and safety information.

In distance selling – particularly in the form of online sales – distributors must provide their customers with the following information about the online offer:

• Name, registered trade name or registered trademark of the manufacturer or the responsible person, if the manufacturer is established outside the EU.
• Postal address of the manufacturer or the responsible person if the manufacturer is established outside the EU.
• Electronic address of the manufacturer or the responsible person if the manufacturer is established outside the EU.
• Product identification information:
  • Type, batch or serial number or any other element that is easily visible and legible to consumers.
  • Images of the product, its type and other product identifiers.
• Required warnings and safety information.

In distance selling – particularly in the form of online sales – products are considered to have been placed on the market as soon as they are offered to consumers in the EU. Such offers to consumers are regularly made by placing the product for sale in an online shop that targets consumers in the EU. In this case, the product is placed on the market when it is placed in the online shop and must meet the applicable requirements of the GPSR. Further information on this can be found in Art. 4 GPSR.

If an economic operator makes products available online, they must provide information such as the name of the manufacturer, their electronic address, as well as warnings and safety information about the product.

The information must be provided in a clearly visible and unambiguous manner alongside the offer. This means that the information must be displayed on the website alongside the product offer. In particular, it must be easy to find and presented in a clearly legible font size. It is important that this information is displayed before the consumer orders the product.

Since safety information in particular can comprise extensive content, it is advisable to embed it in the online offering by means of pop-up windows that can be activated with a click. However, it is not sufficient to refer to the operating instructions or other documents that are physically attached to the product.